Privacy Policy

Effective Date: 10th September 2025

Last Updated: 10th September 2025

Welcome to Fillam. Your privacy is important to us. Fillam want you to understand what

information we collect, and how we use and share it. That’s why we encourage you to read our

Privacy Policy. This Privacy Policy explains how we collect, use, disclose, and safeguard your

information when you use our mobile application, available on Android and iOS platforms. This

Privacy Policy also let you know your rights. Each section of this Policy includes simpler language to make our practices easier to understand.

Introduction

Fillam is a social network focused on film-related content, enabling users to connect, recommend, review, and engage in conversations about movies and TV shows. We are committed to protecting your personal information and your right to privacy. This Privacy Policy outlines how we handle your personal data in compliance with Indian data protection laws, including the Information Technology Act, 2000 and relevant rules.

Data We Collect

Personal Information” refers to any data that can identify an individual, such as name, email, IP address, location data, or other identifiers. We collect the following categories of personal information to offer and enhance our services:

• Basic information such as name, email address, date of birth, gender, city, location, and mobile number during account creation.

• User-generated content including reviews, comments, photos, and recommendations you voluntarily share.

• Profile preferences and interests (e.g., favorite genres or shows).

• Usage data including interactions, device info, and app usage patterns.

• Communication data from in-app chats, messages, or shared content with other users.

• Information from cookies, device tags, or analytics tools to personalize user experience.

• Optional information through surveys or feedback forms.

How Fillam May Use Your Personal Informtion

We use your personal data in a lawful, fair, and transparent manner. Your data is processed for the following purposes:

• To provide customer support and improve user experience.

• To customize recommendations, content, and search results.

• To send alerts, notifications, and updates related to content you follow or engage with.• To enhance community safety by identifying and removing inappropriate content.

• To communicate promotional offers, service updates, or new features.

• To monitor and prevent fraudulent, abusive, or illegal activity.

• To comply with legal, regulatory, or contractual obligations.

• For internal analytics and research to improve our services and engagement features.

• For backup, disaster recovery, and business continuity purposes.

We do not use your data for profiling based on sensitive personal categories unless required by law or you have explicitly consented.

The Basis / Grounds on Which We Rely for Collection and Processing of Your

Personal Information:

Your personal information is collected and processed by Fillam based on the following legal

grounds, depending on the nature of the information and the purposes for which it is processed.

Consent:

Fillam relies on your consent to process your personal information in specific circumstances. Where required by applicable data protection laws, your explicit consent will be obtained at the time of collection for the use of your personal data. Such processing will only be carried out once your consent has been securely obtained and documented.

Compliance with Legal Obligations:

Your personal information may be processed by Fillam where such processing is necessary to comply with a legal obligation. This includes instances where Fillam is required to respond to lawful requests from courts, law enforcement agencies, regulatory authorities, or to retain specific records to meet legal and regulatory compliance requirements under applicable Indian laws.

Information Sharing and Disclosure to Third-Party Services

Fillam may engage certain third-party service providers to help us operate, maintain, and enhance our platform, including the collection and processing of Personal Information. We only share information with third parties to the extent necessary to provide, improve, or secure our services and to comply with legal requirements. We restrict access to your Personal Information to employees and service providers who reasonably need it to fulfill their functions. Fillam does not sell, rent, or trade your Personal Information. We only disclose your information under the following circumstances:

1. Affiliates and Group Companies: - We may share your Personal Information with our affiliates and group companies for internal business, administrative purposes, and service provision.

2. Legal and Regulatory Requirements :- We may disclose information to law enforcement authorities, regulators, or other entities if required by law, court order, or to:

a) Comply with legal obligations;

b) Investigate or prevent fraud, illegal activities, or violations of our Terms;

c) Protect the rights, property, or safety of Fillam, our users, or the public.

3. Third-Party Service Providers:- We may share your Personal Information with trusted third-party vendors who:

a) Provide services on our behalf (such as hosting, analytics, or customer support);

b) Maintain our platform and mailing lists;

c) Facilitate targeted communication or marketing related to our services.

All such providers are bound by strict confidentiality and non-disclosure obligations.

4. Business Transfers:- In the event of a merger, acquisition, financing, or sale of Fillam’s assets, we may transfer your Personal Information to the relevant entity, provided that such entity will continue to respect this Privacy Policy.

5. Third-Party Advertisers (if applicable in future monetization):- If Fillam introduces targeted advertising, certain non-identifiable information may be shared with advertisers to show relevant ads. We do not share personally identifiable information without your explicit consent. Fillam will never transfer your Personal Information to any third party for purposes other than those stated above without your consent, except where legally required.

Sensitive Personal Data or Information (SPDI)

In addition to general personal information, Fillam may collect, and process certain categories of Sensitive Personal Data or Information (SPDI) as defined under the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011. This may include, but is not limited to:

• Passwords or authentication details created for account registration and login.

• Financial information (such as payment details), if Fillam introduces paid features in the future.

• Biometric, health-related, or official identifiers (such as Aadhaar, PAN, or government-issued IDs), if collected in future updates for verification or compliance purposes.

Collection and Use

• SPDI will be collected only where necessary to provide services, ensure account security, or comply with legal obligations.

• Such information will not be used for any purpose other than the one for which it is collected, unless you provide explicit consent.

• You may choose not to provide SPDI; however, this may limit your ability to access certain features of the Fillam platform.

Consent

• By creating an account and using Fillam, you expressly consent to the collection, use, and processing of your SPDI in accordance with this Privacy Policy.

• You may withdraw consent at any time by deleting your account or contacting us at info@fillam.co. Please note that withdrawal of consent may impact the availability of some services.

Security of SPDI

• Fillam implements reasonable security practices and procedures as mandated under

Section 43A of the IT Act, including but not limited to:

• Encryption and hashing of passwords and other sensitive data.

• Restricted access to SPDI, limited only to authorized personnel.

• Secure servers, firewalls, and intrusion detection systems.

• Regular audits and monitoring to detect and prevent unauthorized access.

• Third-party service providers engaged by Fillam are contractually bound to maintain the same level of protection for SPDI.

Third Party Content

The Fillam platform may, from time to time, include links to third-party websites, advertisements, blogs, content sponsorships, vendor services, or social networks. Please note that these external sites are not governed by this Privacy Policy.

Fillam makes no representations or warranties regarding how your information is collected, used, or stored on third-party servers. We strongly encourage you to review the privacy statements and policies of such third-party websites before sharing any personal information. Your interaction with any third-party services will be solely at your own risk.

User Rights

You have the right to exercise your rights available under applicable data protection laws regarding the personal information Fillam processes about you. These rights include the ability to:

• Access your personal information

• Rectify inaccurate or outdated data

• Update or correct your information

• Delete your personal data

• Restrict or object to certain forms of processing

• Request data portability

To exercise these rights, you may contact us at [Insert Privacy Contact Email]. We may require valid proof of identity before fulfilling such requests, to ensure your rights are protected.

Retention of Personal Information

Your personal information will not be retained by Fillam for any longer than is necessary for the purposes for which it was collected and processed, or as required under applicable legal, regulatory, contractual, or statutory obligations. Upon the expiry of such retention periods, your personal information will be securely deleted or archived in accordance with applicable laws and industry standards. You may also delete your data at any time by deleting your profile from the Fillam app or contacting us at [Insert Support Email].

Data Storage and Security

Your data is stored on secure servers in India. We implement industry-standard security measures including:

• Data encryption during transmission

• Secure storage solutions

• Restricted access to user data

• Regular security audits

Cookies and Tracking

We use cookies or device identifiers to maintain sessions, personalize features, and analyze app usage.

Confidentiality and Security

We take the confidentiality and security of your personal information seriously. Fillam implements appropriate technical and organizational measures to safeguard your data:

• Encryption, firewalls, and secure servers protect your personal data.

• Access to user data is strictly limited to authorized personnel on a need-to-know basis.

• We require third-party service providers to adhere to the same security standards when processing data on our behalf.

• Compliance with the Information Technology Act, 2000, and relevant data protection

regulations is maintained.

By using Fillam, you acknowledge and agree that we take all reasonable steps to protect your data.

Social Media

Fillam may operate official pages, channels, or accounts on social media platforms to engage with users and share updates. Please be mindful that any comments, messages, or information you post on our public social media channels are visible to others and may be publicly accessible.

We advise that you do not share sensitive personal information through social media interactions with Fillam. This includes but is not limited to:

• Passwords or authentication details

• Financial information

• Biometric or health-related data

• Official identifiers such as Aadhaar, PAN, or government-issued IDs

Fillam shall not be responsible for any personal information you choose to make public through social media platforms.

Children’s Privacy

To use the Fillam platform, you must be at least the minimum age as specified below or older. The minimum age to access and use Fillam is eighteen (18) years. If local laws in your jurisdiction require a higher minimum age for Fillam to lawfully provide services, that higher age shall apply. If you are under the age of 18 or the age of majority in your jurisdiction, you may only use Fillam under the supervision of a parent, legal guardian, or other responsible adult.

Disclaimer

Fillam does not store any credit/debit card or banking information. We are not responsible for any loss or damage arising from data disclosure, whether inadvertent or otherwise, related to payment transactions processed via external payment gateways.If you share any personal or sensitive information with us beyond what is requested, Fillam will not be liable for any consequences of such disclosure.

Changes to This Policy

We may update this Privacy Policy from time to time. Users will be notified of material changes through in-app notifications or email. Continued use of the app after such updates constitutes acceptance of the revised policy.

Data Protection Officer/ Grievance Officer

In compliance with the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021, Fillam has appointed a Grievance Officer to address user complaints and concerns regarding the processing of personal information. If you have any complaints, grievances, or questions regarding this Privacy Policy or the protection of your personal data, you may contact our Grievance Officer at:

Name: Ankit Rastogi

Designation: Grievance Officer

Email: info@fillam.co

Postal Address: Block 10, Flat 806, AVL36, Sector 36A, Gurgaon 122004, Haryana

The Grievance Officer shall acknowledge your query within 24 hours and endeavor to resolve it

within 15 days from the date of receipt, in accordance with applicable laws.